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What bishops want.

Today, Cardinal Timothy Dolan released a statement outlining the USCCB's objections to the Obama administration's revision of the revision of the contraception mandate. The new rule scotches the previous iteration's much-maligned four-part definition of "religious employer," and proposes arrangements to make sure religious employers -- including colleges, hospitals, and charities -- won't have to pay for or refer for contraception coverage in their employee health plans. In other words, the Department of Health and Human Services listened to its critics and attempted to allay their concerns.

As the editors ofCommonweal put it, "This will do."The U.S. Conference of Catholic Bishops disagrees.

First, a word of praise for the tone of Cardinal Dolan's statement. It avoids the hyperbolic rhetoric that has characterized this debate for far too long. The cardinal states that the bishops are open to further discussion. He acknowledges that the Obama administration "has heard some previously expressed concerns and that it is open to dialogue," and promises "additional, careful study." He notes that the new proposal does away with the "exceedingly narrow" definition of "religious employer," which, the bishops claimed, "created a 'second class' of citizenship within our religious community" -- subordinating Catholic charities to Catholic parishes. But apparently that's not enough for the bishops.

"The administration's proposal maintains its inaccurate distinction among religious ministries. It appears to offer second-class status to our first-class institutions in Catholic health care, Catholic education, and Catholic Charities." Yet Dolan fails to mention what replaced the four-part definition. The USCCB had called that definition "unprecedented" in federal law. So HHS lifted the revised definition from something with plenty of precedent: the federal tax code. According to the new rule, any religiously affiliated employer that has nonprofit status simply has to self-certify with HHS in order to opt out of the contraception mandate. If the employer pays an insurance company for employee health coverage, it has to notify the insurer that it doesn't want contraception included in the plan, and the insurer in turn automatically enrolls employees in a separate plan at no cost to them or to their employer. If the objecting employer is self-insured, it just has to inform its plan administrator, which will arrange for free contraception coverage for employees.

(This is where it gets complicated. "Self-insurance" is a misnomer. Rather than pay an insurance company premiums, some employers prefer to pay directly for their employees' health care. This requires a lot of cash. Such companies typically pay an insurance company to handle administrative tasks. The administrator generates "insurance cards" for the employees, and every time a worker incurs a medical expense, the administrator handles the paperwork and bills the employer for the service, according to an agreed-upon fee schedule. Administration fees are much lower than insurance premiums, so requiring administrators to cover the upfront costs of contraception would be unfair. They'd be paying for savings that accrue only to the "self-insured" company -- covering people who don't want babies is cheaper than covering those who do. That's the financial incentive for insurers to give away contraception to people they already cover. In order to make it worthwhile for administrators of "self-insured" plans, HHS proposes to reduce fees insurance companies will have to pay in order to sell their plans on the new health-care exchanges. Either way, the idea is that no religiously affiliated employer will have to contract for, pay for, or refer for contraception coverage.)

So why does Cardinal Dolan say, "there remains the possibility that ministries may yet be forced to fund and facilitate such morally illicit activities"? No arrangement proposed by HHS would oblige a Catholic institution to fund contraception coverage. But what about "facilitate"? This is the next line of defense. A bishop might argue: Sure, HHS may say that religiously affiliated employers won't have topay for contraception, but there's no getting around the fact that our employees wouldn't receive that coverage if they didn't have the insurance policy we provide. But the Affordable Care Act mandates that everyone have a health-insurance plan -- regardless of employment status. So even if a scrupulous Catholic employer canceled its employee health-care benefit (likely replacing it with cash payments), its workers would still need to buy health insurance -- insurance that would certainly include contraception coverage. The facilitation argument doesn't withstand scrutiny. What's to keep employees from using their salaries to engage in morally illicit acts? Think of all the illicit acts made possible by gainful employment. This is the slipperiest of slopes.

The Catholic tradition developed categories of "cooperation with evil" to help us think through this kind of problem. Without intending the employee to use contraception, without securing or paying for contraception coverage for its employees, a Catholic institution is not involved in a morally illicit act. If an employee wants to use free contraception provided by a third party, that's on her. There's no way to wall off an employee's moral agency. Yet Cardinal Dolan protests that the new proposed rule "would require all employees in our 'accommodated' ministries to have the illicit coverage -- they may not opt out, nor even opt out for their children -- under a separate policy." Cardinal Dolan seems to say that contraception coverage is itself illicit, but the Catholic moral tradition doesn't hold that things in themselves are licit or illicit. Acts are. So Catholic teaching would say that forcing a bishop to provide contraception coverage may be morally illicit. Just as it would say that using contraception is illicit. But the coverage itself has no moral character. It's like saying a drug store shouldn't be selling contraception in a Catholic neighborhood. The availability isn't the problem. An employee may or may not use the free contraception coverage. Until she does, nothing illicit has happened. And if she does, it's not the employer's fault.Cardinal Dolan also expresses his displeasure with the fact that the revised rule does not address the complaints of for-profit employers who have religious objections to the mandate. They "have no conscience protections at all," Dolan writes. Matt Boudway covered this question earlier this week. Should any employer be able to opt out of federally established basic health-insurance benefits because of religious objections? Matt writes:"It would logically lead to a situation they couldn't possibly wish for. Should an overzealous Jehovahs Witness be able to get a group plan that excludes coverage for emergency blood transfusions, even if none of his employees are coreligionists?" The bishops tend to treat conscience claims as though they outweigh everything. In fact, conscience claims must be balanced against state interests (whether the contraception mandate advances a legitimate state interest is another question).

"Throughout the past year," Cardinal Dolan writes in the concluding paragraph, "we have been assured by the administration that we will not have to refer, pay for, or negotiate for the mandated coverage. We remain eager for the Administration to fulfill that pledge." As the bishops continue to study HHS's new proposals, I hope they come to realize that the Obama administration has done just that.

Follow up: Matthew Franck has responded to this post with something shy of full understanding of health insurance. Here's my reply.

"Raber and I are speculating about how his Amish relatives will handle Obamacare."If you are thinking of the individual mandate, as I undertand it, they are exempt. The exemption applies to people who already qualify not to pay Social Secuity taxes because their religion opposes participating in insurance programs. There is also an exemption for members of religious groups that provide free health care for theirI haven't looked into how this applies to Amih employers. Existing law draws a distinction between Amish employers who employee only Amish workers and those who employee non-Amish okers

Jim McRae is right == this whole kerfufle is the greatest advertisement ever for a single payer system.As I see it, there is an inherent contradiction in the legal system. On the one hand, parents have the general responsibility for their minor (immature) children and therefore may and must make moral decisions for them. BUT on the other hand, because of the recession, parents are also responsible (or may assume responsibility) for their post-adolescent children, BUT those post-adolescent children are ALSO responsible for themselves.Thus some parents are both responsible and not-responsible for their post-adolescent kids.

John Hayes, thanks for that info about the personal exemption for the Amish.Really, my larger point is that there are religious organizations that get around these problems by simply opting out and doing for themselves. Their communities are very strong, and their adherents are well versed in the faith. I think the Bishops have been so unwilling to accept offered accommodations because they know that most Catholics do not follow Church teaching on contraception. Perhaps they see Obamacare mandates as a "teaching moment," as I noted in an earlier post, to show the faithful that they mean business about these rules. My question--I don't know the answer--is whether their time is well spent debating this issue through press releases and public statements.? Or by trying to build the sense of community some of the more insular denominations (like the Amish or Jehovah's Witnesses) have would set norms and motivate Catholics to follow the rules as a matter of course.If the Seventh Day Adventists can keep their adherents off the cigs, I'm pretty sure Catholics could figure out ways to keep folks off the Pill and out of the condom aisle at the drug store.

Jim Pauwels: what if your daughter were the friend who motivated Sandra Fluke to speak out? Fluke described a friend who was taking a prescription contraceptive to control the growth of an ovarian cyst. When she could no longer get the prescription medication free and could not afford to buy it, the cyst began to grow until her entire ovary had to be removed surgically. If your unmarried daughter were a dependent on your insurance plan, would you be so hardhearted as to forbid her to obtain the Pill for some other purpose than avoiding pregnancy, on the off-chance that she might have sex while taking it?

Re: Culture Warrior ChaputHis family background: father, French Canadian and mother, Native American.Archbishop Chaput is member of the Prairie Band Potawatomi tribe through his mothers Native-American lineage. His Potawatomi name is the wind that rustles the leaves of the tree. His surname, Chaput, a variant of Chapel and a nickname for a habitual wearer of a distinctive cloak or hat.It figures, doesn't It?

Angela Stockton, i think some Catholic institutions say that their healh insurance will pay for contraceptives used to treat medical problems but not if they are used only for birth control. i suppose (but haven't verified) that they could continue to do that. Paying for some uses of contraceptives but not others creates an awkward situation for the employee. Doctors don't write on a prescription why they are prescribing that drug. However, the insurance company would have to know whether to charge the cost to the employer's policy that covers some uses of contraceptives or the separate third-party policy that covers other uses. Sounds as if the employee would have to submit a statement from the doctor as to why the pills were being prescribed.

Some day in the future, bishops will reminisce about Tim Dolan and company and say that they meant well. That they felt they had to protect the church's rights. That they really thought that contraception was wrong. That it was a threat to the infallibility of the church which was held at that time. So apolgies to all those families that they thought they were helping. ..............

Perhaps Cardinal Dolan needs to be reminded that many employees of Catholic hospitals, colleges and social service agencies already are eligible to received government-subsidized contraceptives either through Medicare or Title X of the Public Health Act (1970). Income eligibility for a family of four --in most states-- is $41,319.Doesn't the HHS "mandate" simply remove the salary ceiling on employee eligibility for government subsidized contraceptives? (In the future, the "professional staff" will have access to the same government subsidy that the "housekeeping staff" now has access to.)This raises the question: Aren't Catholic institutions engaged in "material cooperation" by "qualifying" their employees for the "illicit coverage" provided by Medicare and Title X? (The moral solution is simple: pay higher salaries and make their employees ineligible for government-subsidized contraceptives!)

"i think some Catholic institutions say that their health insurance will pay for contraceptives used to treat medical problems but not if they are used only for birth control. i suppose (but havent verified) that they could continue to do that."Would be interesting to know if those who provide "Catholic insurance" have employees with a higher rate of ailments for which b.c. pills are prescribed for "therapeutic" use, say something really vague like "dysmenorrhea." I suppose Catholics providing the insurance would not be complicit in this particular scenario, just as they wouldn't be culpable if women in their 40s take "hormone replacement therapy" for menopausal symptoms (my Lord, how DID our grandmothers deal without hormones!?), which have the effect of preventing an unwanted mid-life pregnancy.Am I wrong to think that all of this smacks of a kind of moral gamesmanship that doesn't fool anybody?

I wonder if this is good for the HHS mandate. By keeping the media focused on an issue that, in the view of most people, is a non-issue, the Catholic bishops are preventing people from discussing other potential and perhaps more substantial problems.

I think it is good to stay aware of what the discussion outside the Catholic bubble is like about Catholic hierarchs and and their anti-feminine contraception campaign.The answer is for Church organizations to mind their own business and stay out of people's bedrooms.Oh wait -- that's exactly what they are asking to be able to do, to be kept out of people's private sexual affairs. To not be involved and especially to not have to subsidize the sexual activities of people, especially those activities which operate to suppress that which is feminine. ("anti-feminine contraception" -- that is exactly right, it is contraception which is by its nature anti-feminine. To oppose subsidizing contraception is, in fact, anti-anti-feminine)If anyone should be subsidizing women's contraception, it should be the MEN who have sex with the women.

"I wonder if this is good for the HHS mandate. By keeping the media focused on an issue that, in the view of most people, is a non-issue, the Catholic bishops are preventing people from discussing other potential and perhaps more substantial problems."I'm sure it's not good for the HHS mandate, but not sure I follow your point. Problems like what?"To not be involved and especially to not have to subsidize the sexual activities of people, especially those activities which operate to suppress that which is feminine. ('anti-feminine contraception' that is exactly right, it is contraception which is by its nature anti-feminine. To oppose subsidizing contraception is, in fact, anti-anti-feminine)"So if "feminine" = conception, i.e., that which can conceive, carry, and nurse babies, where does that leave celibate women. Do they become anti-feminine if they choose not to use their procreative powers? What about older women past child-bearing years? Do they turn into drones? You poor guys sometimes you shoot yourselves in the foot when you try to explain the "feminine," and that's gotta hurt. At least I hope it does.

John Hayes, according to Sandra Fluke's testimony, Georgetown does make an exception for women who need the pill to treat serious diseases. Unfortunately, she says they are so concerned to prevent people sneaking in contraception that they don't accept a doctor's letter that the pill is a medical necessity. Rather, they open an inquiry to see if the pill is really necessary- and, academic bureaucrats being what they are, the inquiry takes weeks, even months, and in some cases the disease progressed so much that treatment was no longer possible before the Georgetown officials had made up their minds whether to allow the pill or not.It's a major issue for me that if the bishops win this fight they should address this problem- i.e. make a commitment to accept a doctor's letter immediately even at the risk of somebody sneaking some contraception. It's unacceptable to me that a young woman be unnecessarily sterilized and subjected to premature menopause as the price of making double and triple sure that nobody sneaks a contraceptive through the system.

"If anyone should be subsidizing womens contraception, it should be the MEN who have sex with the women."Bender --This time I half-way agree with you. Surely it makes less sense to have some Jesuit pay for a woman's contraceptives than to have her sexual partner pay.On the other hand, the new rules of the new let's-be-fair feminism require that men and women are supposed to split the check when they share a pleasurable meal. It's downright old-fashioned to expect the guy to pay for both dinners. So it would seem to follow, since sex is a shared pleasure, shouldn't the new women split the cost of contraceptives with their partners? (Georgetown really gets nada from their encounters, so of course it shouldn't have to pay at all.) But that would get complicated if she has more than one partner a month -- should the guys each pay one quarter of the cost? This gets to be a complicated as the HHS mandate problems. See what happens when you expect non-participants to pay for somebody else's jollies?

Ann Olivier, I looked p Sandra Fluke' testimony. Heres what she is reported to have said:"When this exception does exist, these exceptions don't accomplish their well-intended goals, because when you let university administrators or other employers, rather than women and their doctors, dictate whose medical needs are legitimate and whose are not, a woman's health takes a backseat to a bureaucracy focused on policing her body. In 65 percent of the cases at our school, our female students were interrogated by insurance representatives and university medical staff about why they needed prescriptions and whether they were lying about their symptoms. For my friend, and 20 percent of the women in her situation, she never got the insurance company to cover her prescription. Despite verification of her illness from her doctor, her claim was denied repeatedly on the assumption that she really wanted birth control to prevent pregnancy. She's gay -- so clearly, polycystic ovarian syndrome was a much more urgent concern than accidental pregnancy for her.After months of paying over $100 out of pocket, she just couldn't afford her medication anymore, and she had to stop taking it. I learned about all of this when I walked out of a test and got a message from her that, in the middle of the night in her final-exam period, she'd been in the emergency room. She'd been there all night in just terrible, excruciating pain. She wrote to me: "It was so painful I woke up thinking I'd been shot." Without her taking the birth control, a massive cyst the size of a tennis When this exception does exist, these exceptions don't accomplish their well-intended goals, because when you let university administrators or other employers, rather than women and their doctors, dictate whose medical needs are legitimate and whose are not, a woman's health takes a backseat to a bureaucracy focused on policing her body. In 65 percent of the cases at our school, our female students were interrogated by insurance representatives and university medical staff about why they needed prescriptions and whether they were lying about their symptoms. For my friend, and 20 percent of the women in her situation, she never got the insurance company to cover her prescription. Despite verification of her illness from her doctor, her claim was denied repeatedly on the assumption that she really wanted birth control to prevent pregnancy. She's gay -- so clearly, polycystic ovarian syndrome was a much more urgent concern than accidental pregnancy for her."http://www.politifact.com/truth-o-meter/article/2012/mar/06/context-sand...

Sorry, mixed up the copy and paste? Here's the correct second paragraph:"After months of paying over $100 out of pocket, she just couldn't afford her medication anymore, and she had to stop taking it. I learned about all of this when I walked out of a test and got a message from her that, in the middle of the night in her final-exam period, she'd been in the emergency room. She'd been there all night in just terrible, excruciating pain. She wrote to me: "It was so painful I woke up thinking I'd been shot." Without her taking the birth control, a massive cyst the size of a tennis ball had grown on her ovary. She had to have surgery to remove her entire ovary as a result. On the morning I was originally scheduled to give this testimony, she was sitting in a doctor's office trying to cope with the consequences of this medical catastrophe."

Thanks, John Hayes, but I was really asking if Ms. Flacke's purported facts and figures had been checked out by others. In other words, has her testimony been verified by other evidence? I just can't believe the Jesuits would have such a stupid policy. But I could be wrong :-)

I just spent less than a minute on Google and a mapping program, and discovered that there is a Planned Parenthood clinic about two miles away from Georgetown's campus. Did her friend pursue that avenue? If, as has been reported here, she had a note from her doctor, I would find it pretty amazing to learn that Planned Parenthood wouldn't have helped her.http://maps.yahoo.com/directions/?q=3700%20O%20St%20NW%20%20Washington%2...

"a womans health takes a backseat to a bureaucracy focused on policing her body."I think is is only half fair: The bureaucracy is focused on policing its determination NOT to collude in contraception."I would find it pretty amazing to learn that Planned Parenthood wouldnt have helped her."I think people need to understand how PP and other family planning clinics work before offering this type of advice.In the first place many such clinics often do not have dispensaries where you can just take a scrip for hormones and have it filled for free. Larger clinics that might offer a dispensary will charge for the pills on a sliding scale. This is unfair if the woman's insurance company covers non-contraceptive hormone therapy treatments.In the second place, PP and similar clinics specialize in contraception and abortions; staff are not very good at diagnosing other gynecological problems, and they generally refer patients elsewhere for treatment for those conditions. In the third place, the patient may have her own moral qualms about PP's mission. Wouldn't a Catholic patient rightfully fear colluding with evil paying for services from such a clinic?The best recourse a woman in this situation has is to pay for her prescription out of pocket ASAP so that her cystic condition doesn't worsen to the point where she needs surgery or, God forbid, a cyst ruptures causing excruciating pain and possibly serious infection. If I were that woman's friend, I would try to help her with the cost of her meds and hope that the employer who is withholding treatment she has paid for and deserves will get sorted out in the Hereafter.

John Hayes --The best DeGioia manages to say about Fluke is tht she is sincere. And neither did he say tht she correctly described Georgetown's policy. Further, given Jim Pawells point about the family planning clinic not far away, I still can't believe that her perception of the whole situation is reliable. if the situation really was so dire for her friend and if she really cared about her friend she would have found a ride for her to that clinic. There are lots of Georgetown students with cars.

Ann, you're ignoring a) that Planned Parenthood or a similar clinic that specializes in contraception is not going to be a fix-it for this, and b) this woman has paid for or earned her insurance benefits and has a bona fide medical condition that could be straightened out with hormone therapy. She does not intend to use the medication to get illicit "jollies." Why should she be denied or jacked around about getting something she has earned? Guess I'll add birth control to my list of things I should stop talking with Catholics about.

Phew! Georgetown was spared the possibility that it might indirectly and unintentionally collude in someone's practice of contraception, and it only cost this woman (and how many others?) significant pain and unnecessary surgery. WAY better that women be cut up than that Georgetown students might get access to contraception on campus, right? After all, if you give women and their doctors control over their medical decisions, well, that can't be good. Women just can't be trusted when it comes to morality, after all. Eve and all that...Does it matter how many women have unnecessary surgery? Or is it enough that this policy led to one woman having unnecessary surgery?The problem here, istm, isn't that the woman could have found a work-around if she'd tried harder. The problem is that she would have had to, while if she'd gone to a secular school she'd likely still have both ovaries. Should the result of choosing Catholic education be mutilation?

OK, my last comment, I promise, then I'm off all pelvic discussions, to the relief of all concerned.But women with polycystic ovarian disease or endometriosis, another condition that hormones are sometimes used to treat, are usually already infertile. So taking hormones that render them sterile is moot. And the spectacle of Catholics on this blog suggesting that women to go to Planned Parenthood for a work-around is truly astounding.

Jean --Why not go to Planned Parenhood to get help if you're desperate? Some of what PP does is quite moral. My purpose in entering this discussion was simply to question whethr the Georgetown studen't's testimony was entirely credible. I didn't find it to be. That does not imply that, had Georgetown given her the run around it would have been right. But on the other hand, franklly Ms. Fluke sounds quite holier-than-thou because she could have gotten her friend to Planned Parenthood or some other agency for the needed help. But obviously she didn't.

Ann Olivier, here is this year's version of the doctor certification form that Georgetown requires if you want their plan to pay for contraceptives for non birth control use:http://studentaffairs.georgetown.edu/insurance/medication-override.pdfAs I understand her testimony, Georgetown makes extensive enquiries before approving the prescription even after reveiving this form. To find this, you have to go here in the student helth plan bookletQ. Are medications to prevent pregnancy or procedures to prevent or terminate pregnancy covered?A. No, medications and procedures for birth control are not covered. The following notice is required by the Patient Protection and Affordable Care Act:NOTICE TO PLAN PARTICIPANTS The organization that sponsors your health plan has certified that it qualifies for a temporary enforcement safe harbor with respect to the Federal requirement to cover contraceptive services without cost sharing. During this one-year period, coverage under your health plan will not include coverage of contraceptive services.Q. Are medications to prevent pregnancy covered when prescribed for treatment of a covered sickness?A. Yes, your health care provider can document the medical necessity and a medical override for non-contraceptive reasons may allow for insurance coverage. To purchase such medications with your Pharmacy Card, ask providers outside of the GU Student Health Center (SHC) to complete the Medication Override Form and fax it to Gallagher Koster Insurance Agency, 617-479-0860. Note: The SHC will submit the Medication Override for you.

Ann Olivier, it looks like that, but what Sandra Fluke testified was:"In 65 percent of the cases at our school, our female students were interrogated by insurance representatives and university medical staff about why they needed prescriptions and whether they were lying about their symptoms. For my friend, and 20 percent of the women in her situation, she never got the insurance company to cover her prescription. Despite verification of her illness from her doctor, her claim was denied repeatedly on the assumption that she really wanted birth control to prevent pregnancy"

Ann Olivier. She testified representing. Group called Georgetown Law Students or Reproductive Justice. Seems likely that they did a survey on campus and came up with those figures. In my Googling I didn't find anyone who questioned the figures. Nothing from Georgetown saying "it's just not right that we reject 20% of applications - last year we approved 98% of applications. And we don't imply that you are lying about your symptoms to get free contraceptives."Her presentation is a little unclear to me because she may be mixing together people who submit a letter from an outside doctor and people who never get a letter because they went to an internal Georgetown doctor who didn't agree they have a medical condition.Whatever tne numbers, this kind of conflict seems inherent in a situation in which an employer says "we'll pay for this drug but only if you convince us that it's for a non-sinful use."

Thanks for the input, John. You have a point. DiGioia didn't deny her figures. So who knows. I did see some of her testimony on TV, but didn't watch the whole thing since what I did see didn't impress me, but that was just an impression of her body language.

"In 65 percent of the cases at our school, our female students were interrogated by insurance representatives and university medical staff about why they needed prescriptions and whether they were lying about their symptoms."I suppose I'm not the only person to spot the contradiction inherent in this non-testimony.Why would an insurance company "interrogate" a patient about the symptoms for contraceptive medication?After all, we've been told that the entire financial basis of the Obama Administration's accommodation is that birth control saves insurers money. It's always cheaper for the insurer, we're assured, for women to utilize contraception than for them to become pregnant. To carry this notion to its logical conclusion, one would expect that insurance companies would do everything within their legal powers to get their female patients of child-bearing years onto birth control. Insurance companies, one would think, would want women popping them like vitamin supplements with their breakfasts in the morning.

Just one more thought on Fluke and her anecdote. I have no reason to question the essential facts. I can easily believe that bureaucratic mismanagement resulted in this woman becoming much more seriously ill than was necessary. It sounds like a horrible thing, and I hope that she is now healed and did not suffer a financial or an academic-progress setback.I spent a very little time looking for a public statement from DiGioia, the Georgetown President, defending his student heath policy against Fluke's charges. I haven't found one. So it seems possible that Fluke isn't exaggerating to make a point.It strikes me as a solvable problem. I'd like to think that DiGioia, upon learning about this situation, immediately did whatever is in his considerable power to ensure that it never happens again to a member of the Georgetown community. It seems eminently reasonable that a doctor's note should suffice to get a prescription filled on the spot for medication for a serious condition. No additional forms or visits should be necessary. I'd think, given DiGioia's position, he could make that policy change happen. And perhaps he has.Note, though, what isn't necessary to solve this problem. What isn't necessary is a frickin' *federal agency mandate* that binds virtually every employer in the land, misdefines what constitutes a religious organization, creates a firestorm of controversy, requires an "accommodation" that doesn't satisfy the intended recipients, implicates insurance companies and third party administrators, generates lifetime employment for a lot of lawyers, and causses everything else that has come about because of the HHS mandate. A stroke of a college president's pen could solve a local problem. And that could have been the end of it.

Gerelyn - what does the link you provided illustrate regarding insurers, or insurance representatives?The link that John Hayes provided is to a form belonging to a third party benefits administrator called Gallagher Koster. I'm not sure what that tells us, except that Georgetown uses a third party administrator for certain student health benefits. It may mean that Georgetown is self-insured. Or not.